Please strongly reconsider…

Please strongly reconsider the proposed changes. Although I understand that you are trying to balance other competing issues, for the longevity of humankind it is critical to protect biodiversity.

As a concerned citizen, I strongly oppose the proposed rule to change the long-standing definition of “harm” under the Endangered Species Act (ESA). The current definition, supported by sound science and legal interpretation, appropriately recognizes that habitat modification and destruction can cause harm to threatened and endangered species. Excluding habitat modification from the definition of harm could drastically weaken one of the ESA’s most effective and widely used protections. Without question, this change could threaten the survival and recovery of endangered species, and could inadvertently fast track many species onto the list. Species we cannot afford to lose. Additionally, the recovery of listed species could become much more difficult and costly as more essential habitat could be impacted or lost. Protecting habitat is essential to avoid future ESA listings.

There is long-standing scientific documentation that habitat destruction, fragmentation, and degradation are the leading cause of species declines in the US and globally. It is not only over-harvesting or direct impacts to individual plants and animals that result in the decline of a species. The greatest threats – the degradation and loss of their habitat, critical feeding, sheltering, breeding, and/or nesting grounds – bring species to the brink of extinction. Furthermore, the current interpretation of the definition of harm, to include impacts to habitats, has been utilized by the USFWS for decades. This interpretation has even been upheld in a case before the US Supreme Court.

In Illinois, the survival of federally endangered species, like the Piping Plover (Charadrius melodus), over a dozen mussel species, the Indiana (Myotis sodalis) and Northern Long-Eared Bat (Myotis septentrionalis), and the Rusty Patched Bumble Bee (Bombus affinis), are dependent on the ESA protections offered to these species, including protections to the habitats on which they depend. I urge the U.S. Fish and Wildlife Service and the National Marine Fisheries Service to withdraw this proposed rule and maintain the current definition of “harm” to ensure the continued protection of our nation’s most vulnerable wildlife.

Thank you for prioritizing the long term health of Earth,
Rachel